Open Recommendations

Sensitive But Unclassified.

Sensitive But Unclassified.

SENSITIVE BUT UNCLASSIFIED

We recommend that the Indian Health Service develop policies and procedures to communicate to Tribes that HHS employees assigned to Tribal health programs met the background investigation requirements of the ICPFVPA and inform Tribes that Federal background investigation criminal history results may not cover more stringent character standards that Tribes may adopt as allowed by the ICPFVPA.

We recommend that the Indian Health Service provide Tribes with documentation that confirms that current HHS employees assigned to Tribal health programs met all background investigation requirements of the ICPFVPA.

We recommend that the Indian Health Service develop and offer a nationwide training seminar to Tribes on background investigation requirements of the ICPFVPA.

We recommend that the Indian Health Service enhance Single Audit Compliance Supplement, part 4: "Agency Program Requirements," for Tribes receiving ISDEAA funds from IHS by: establishing special tests and audit procedures in the annual Single Audit Compliance Supplement for all its ISDEAA programs to ensure that the ICPFVPA's requirements are tested during a review of a Tribal health program as part of the single audit, and reviewing the results of those special tests and audit procedures in the annual single audits for Tribal health programs to help assess whether Tribes are complying with ICPFVPA requirements to conduct background investigations and…

We recommend that the Cherokee Nation develop and implement policies and procedures to ensure that: all individuals, including contractors and volunteers, in contact with Indian children are fingerprinted prior to starting employment, illegible fingerprints are retaken and resubmitted to FBI until a background investigation is completed in accordance with the requirements of the ICPFVPA, background investigations of contractors, including HHS employees, are reviewed or performed as required by the ICPFVPA and Tribal policies, and criminal history results are assessed to verify that applicants meet the required minimum character standards.

We recommend that the Cherokee Nation request and review agency contractor background investigations that comply with the ICPFVPA, including documentation that confirms HHS employees met all background investigation requirements of the ICPFVPA, or perform background investigations on these individuals that comply with the ICPFVPA.

We recommend that the Cherokee Nation identify employees and volunteers outside our sample who lack evidence that a background investigation was performed, as required by the ICPFVPA, and who currently have contact with Indian children and perform the required background investigation and determine whether these individuals meet the required minimum character standards.

We recommend that the Cherokee Nation perform background investigations, as required by the ICPFVPA, on the employees and volunteers we identified as not having complete background investigations who currently have contact with Indian children and determine whether these individuals meet the required minimum character standards.

We recommend that the Choctaw Nation develop and implement policies and procedures that ensure that the Tribe follows the requirements of the ICPFVPA to: collect information about the applicants' previous 5 years of residency, conduct FBI fingerprint background investigations using FBI-approved procedures for all individuals in contact with Indian children, conduct inquiries to State and Tribal law enforcement agencies about the applicants' previous 5 years of residency, and assess criminal history results to verify that applicants meet the required minimum character standards.

We recommend that the Choctaw Nation request and review agency contractor background investigations that comply with the ICPFVPA, including documentation that confirms HHS employees met all background investigation requirements of the ICPFVPA, or perform background investigations on these individuals that comply with the ICPFVPA.

We recommend that the Choctaw Nation perform background investigations, as required by the ICPFVPA, on all employees and temporary employees who currently have contact with Indian children and determine whether these individuals meet the required minimum character standards.

Require Serve DC to develop and implement policies and procedures to appropriately track in its accounting system and obtain supporting documentation for all in-kind match costs associated with AmeriCorps grants and from within the DC government and third parties.

Require Serve DC to implement controls to prepare reports that support and reconcile to the amounts reported to AmeriCorps eGrants. Serve DC should also establish controls to reconcile and document costs recorded in the accounting record to the costs reported on the Federal Financial Report for each grant.

Require that Serve DC develop and implement a mandatory training program including a tracking system to ensure that all subgrantees’ staff have training, capability, and assistance to enter their budgets and costs into its reporting system to meet reporting requirements timely.

We are referring $8,534 in questioned costs for further review and action. The questioned costs consist of
credit card purchases for which LAW did not maintain adequate documentation to support the purposes of
the transactions or explain why they were allowable under LSC regulations and guidance.

(U) Rec. 3: The DoD OIG recommended the Under Secretary of Defense for Policy coordinate with the Department of State to develop and implement a process to provide the Defense Security Cooperation Agency, as well as the divesting and receiving country's Security Cooperation Offices, with documentation of third party transfer approvals of enhanced end use monitoring defense articles in advance of transfer.

(U) Rec. 4: The DoD OIG recommended the Defense Security Cooperation Agency Director and the Military Department implementing agencies develop and implement a system to update the Security Cooperation Information Portal-End Use Monitoring database with the serial numbers of all enhanced end use monitoring defense articles provided to Ukraine to confirm the accuracy and completeness of the database and the total number of enhanced end use monitoring defense articles provided to Ukraine.

(U) Rec. 4: The DoD OIG recommended the Defense Security Cooperation Agency Director and the Military Department implementing agencies develop and implement a system to update the Security Cooperation Information Portal-End Use Monitoring database with the serial numbers of all enhanced end use monitoring defense articles provided to Ukraine to confirm the accuracy and completeness of the database and the total number of enhanced end use monitoring defense articles provided to Ukraine.

(U) Rec. 5.a: The DoD OIG recommended the Defense Security Cooperation Agency Director develop and implement a system of internal controls to verify that all inventories and serial number notifications provided to the Security Cooperation Information Portal-End Use Monitoring Help Desk are accurately updated in the Security Cooperation Information Portal-End Use Monitoring database within a required timeframe.

(U) Rec. 5.b: The DoD OIG recommended the Defense Security Cooperation Agency Director: Revise the Security Assistance Management Manual to reflect the role that the Security Cooperation Information Portal-End Use Monitoring Help Desk plays in maintaining responsibility for updating the Security Cooperation Information Portal-End Use Monitoring database with barcode scanner data, in accordance with current procedures and authorities.

We recommend the CISA Director develop and implement comprehensive policies and procedures regarding its collaboration with EPA and other Water and Wastewater Systems Sector stakeholders. These policies and procedures should address: • the Water Sector Liaison’s roles and responsibilities; • what information should be shared with stakeholders; • how often and when divisions should coordinate their communications; and • how best to facilitate information sharing about cyber threats, vulnerabilities, incidents, potential protective measures, and best practices, in both routine and urgent circumstances.

We recommend the CISA Director have an agency-wide requirement to develop and implement standard operating procedures to improve regular communication among CISA divisions relevant to the Water and Wastewater Sector or other critical infrastructure Sectors and share that information and updates on projects, decisions, and lead roles and responsibilities related to the Water and Wastewater Systems Sector and other sectors as appropriate.